FAQs: What Are the Documentation Requirements for NP and PA Students?

Question: We have nurse practitioner students who rotate through our practice. Can we use their notes in the same way medical student notes are used?
Answer: Great question! Rules for nurse practitioner and physician’s assistant students documentation have changed in the last couple of years. As of January 1, 2020, clinicians can now use notes written by students. Specifically, when providing professional services, clinicians may now review and verify notes in a patient’s medical record made by other physicians, residents, nurses, students and other medical team members rather than re-documenting the information.

The change in documentation requirements developed after a 2018 rule change by the Centers for Medicare and Medicaid Services (CMS) reduced the burden of documentation for clinicians but also created unintended consequences for nurse practitioner and physician assistant preceptors and the students under their supervision. As a result, many clinicians abruptly stopped precepting which created a disruption in education for NP and PA students. The American Academy of Nurse Practitioners (AANP), the American Academy of Physician Assistants (AAPA), nursing and physician stakeholders began rallying for changes to the 2020 final rule.

The efforts by these groups proved effective and in November 2019, CMS revised the Medicare Claims Processing Manual, Chapter 12 Section 100.1.1 to update the policy on Evaluation and Management documentation. The policy now allows documentation by students and other medical team members to be verified by the acting clinician. The clinician must perform or re-perform the physical examination and all medical decision-making activities for the patient but no longer has to re-document notes from a student assisting in the medical services. 

This rule change aligns with today’s productivity demands for medical clinicians while also improving patient access to high quality care. 




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